Primavera Systems, Inc

The alleged violations occurred between November 2002 and July 2005. OFAC alleged that Primavera acted without an OFAC license when it exported goods and services to Primavera’s Dubai, U.A.E. based authorized representative with knowledge that the goods and services were destined for re-export to Iran.

Pinnacle Aircraft Parts Inc

OFAC alleged that Pinnacle failed to provide documents responsive to an administrative subpoena issued by OFAC as part of its investigation of Pinnacle’s February 2004 sale and delivery of a jet engine, with a value in excess of $1 million. The engine appears to have been destined for Iran.